The entry-level driver training rule changed who is allowed to sit a CDL skills test. Since February 2022, a first-time Class A or Class B applicant has to complete training from a provider on a federal registry before taking the test. The rule also contains four exemptions, two grandfather provisions and a one-year window that catches people who split their training across a long period. This page works through 49 CFR Part 380 Subpart F.
Who the rule applies to
Section 380.603(a) applies the subpart to all entry-level drivers, as defined in the subpart, who intend to drive commercial motor vehicles as defined in 383.5 in interstate and/or intrastate commerce. Both kinds of commerce: this is not an interstate-only rule.
Section 380.605 defines an entry-level driver as an individual who must complete the CDL skills test requirements under 383.71 before receiving a CDL for the first time, upgrading to a Class A or Class B CDL, or obtaining a hazardous materials, passenger or school bus endorsement for the first time. The same definition excludes individuals for whom states waive the CDL skills test under 383.77 and individuals seeking to remove a restriction under 383.135(b)(7).
Section 380.609 then states the operative requirement in two parts. Under (a), an individual applying for the first time for a Class A or Class B CDL, or upgrading to one, must complete driver training from a provider listed on the Training Provider Registry. Under (b), an individual seeking a passenger (P), school bus (S) or hazardous materials (H) endorsement for the first time must complete the training related to that endorsement from a TPR-listed provider.
The four exemptions
Section 380.603(a)(1) to (4) lists them:
- drivers excepted from the CDL requirements under 383.3(c), (d) and (h);
- drivers applying for a restricted CDL under 383.3(e) through (g);
- military personnel with military CMV experience who meet all the requirements and conditions of 383.77;
- drivers applying for removal of a restriction in accordance with 383.135(b)(7).
The military exemption is conditional on meeting all the requirements of 383.77, not merely on having driven military vehicles.
The grandfather dates
Section 380.603(b): drivers issued a Class A CDL, Class B CDL, or a passenger (P), school bus (S) or hazardous materials (H) endorsement before 7 February 2022 are not required to comply with the subpart as it pertains to that CDL or endorsement. The scope is per credential. Holding a grandfathered Class B does not exempt you from ELDT when you upgrade to a Class A, because 380.609(a) covers upgrades explicitly.
Section 380.603(c) handles learner's permits. Under (c)(1), individuals who obtained a CLP before 7 February 2022 are not required to comply if they obtain a CDL before the CLP or renewed CLP expires. Under (c)(2), individuals who obtain a CLP on or after that date are required to comply.
The one-year window
Section 380.603(c)(3) is the provision most likely to catch a part-time trainee. Except for individuals seeking the H endorsement, individuals must complete the theory and the behind-the-wheel (range and public road) portions of entry-level driver training within one year of completing the first portion.
So finishing theory in March and starting behind-the-wheel training the following April is too late, and the theory has to be redone. Anyone spreading training around a job should plan against that date.
Theory and behind-the-wheel: what they are, and who may split them
Section 380.605 defines both. Theory instruction is knowledge instruction on the operation of a CMV and related matters provided by a theory instructor through lectures, demonstrations, audio-visual presentations, computer-based instruction, driving simulation devices, online training or similar means.
Behind-the-wheel range training is training provided by a BTW instructor when the entry-level driver has actual control of the power unit during a lesson on a range; BTW public road training is the same on a public road. Both definitions carry the same exclusion, and it is worth quoting: BTW training does not include the time the driver spends observing the operation of a CMV when not in control of the vehicle. Ride-along time is not BTW time.
Section 380.707(c) governs splitting: separate training providers may deliver the theory and the BTW portions, but both portions of the BTW training — range and public road — must be delivered by the same training provider. You may buy theory online from one provider and BTW from another. You may not split range and road between two providers.
Instructor qualifications
Section 380.713 requires theory training providers to use instructors who are theory instructors as defined in 380.605, and BTW providers to use BTW instructors as defined there. The definitions set real bars.
A BTW instructor must hold a CDL of the same or higher class with all endorsements necessary to operate the vehicle being trained on, and have either at least 2 years of experience driving a CMV requiring a CDL of that class or endorsement, or at least 2 years of experience as a BTW CMV instructor, and must meet all applicable state qualification requirements for CMV instructors. An exception applies to range-only instructors: they need not currently hold the CDL provided they previously held one of the same or higher class with the necessary endorsements and comply with the other requirements.
A theory instructor is defined on the same two-year basis, with two exceptions: an instructor who previously held the appropriate CDL need not currently hold it, and providers offering online content exclusively are not required to meet state qualification requirements for theory instructors.
Both definitions carry the same disqualification: if an instructor's CDL has been cancelled, suspended or revoked due to any of the disqualifying offenses in 383.51, that person is prohibited from instructing for 2 years following the date the CDL is reinstated.
What the trainee has to produce, and what gets reported
Section 380.707(a) puts two duties on the provider before BTW training starts. It must require all accepted BTW applicants to certify that they will comply with DOT regulations in Parts 40, 382, 383 and 391, as well as state and local laws, relating to controlled substances testing, age, medical certification, licensing and driving record. And it must verify that all accepted BTW applicants, or Class A theory instruction upgrade curriculum applicants, hold a valid commercial learner's permit or commercial driver's license as applicable.
Section 380.717 then requires the provider, by midnight of the second business day after the trainee completes training, to electronically transmit certification information through the TPR website including: the trainee's name, licence or permit number and state of licensure; the CDL class and/or endorsement and the type of training completed (theory and/or BTW); the total number of clock hours spent on BTW training, as applicable; the provider's name and unique TPR identification number; and the dates of successful training completion.
That second-business-day deadline matters to a trainee with a skills test booked: the state cannot see the completion until the provider files it.
Choosing a school
Unlike most categories in this directory, there is a single bright-line federal test here: is the provider listed on the Training Provider Registry? Section 380.609 makes training from a listed provider the requirement, and 380.703 sets out what listing involves. Beyond that:
- Ask for the TPR number. 380.703(a)(7) issues a unique TPR number per campus or training location, so a multi-site school has more than one and the one that matters is the site you will attend.
- Confirm who delivers the BTW range and road portions. 380.707(c) requires the same provider for both.
- Ask how BTW hours are counted. Observation time is excluded by the definitions in 380.605.
- Check the filing deadline. 380.717 gives the provider until midnight of the second business day after completion, and your skills test appointment depends on it.
- Mind the one-year window in 380.603(c)(3) if you are splitting theory and BTW across a period.